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Checklist
How do we lawfully monitor workers?
Checklist
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We have checked that the monitoring of workers is necessary for the purpose we have identified and are satisfied there is no other reasonable and less intrusive way to achieve that purpose.
We have considered whether we need to do a DPIA and either completed the
DPIA or documented the reason we considered one wasn’t required.
When making our DPIA decision, we have considered seeking the views of workers and representatives and either undertaken this or documented our decision not to.
We have identified a lawful basis for monitoring workers.
Where required, we have identified an appropriate special category condition for monitoring workers if we’re likely to capture any special category data as part of our monitoring.
We have documented what data we are processing when we monitor workers.
Where required, we have an appropriate policy document in place.
We included specific information about monitoring workers in our privacy information so that workers are aware of any monitoring taking place.
If we use the data from monitoring workers for automated decision making (including profiling), we have checked we comply with Article 22.
Where we use automation with human involvement, we ensure the involvement is meaningful.
We have considered whether the risks associated with monitoring workers affects our other obligations around data minimisation, security, and appointing data protection officers (DPOs) and representatives.
We have considered data protection issues as part of the design and implementation of monitoring systems and practices, including where we use external suppliers for monitoring technology, and where we use the functionalities built into communication and collaboration work tools.
Where necessary, we have considered the rules for international transfers.
